CTC - Corporate Trade Compliance
- Ensure Management's commitment and awareness throughout the company
- Provide the frame for a trade compliance program (Corporate Policies, Organization, Resources, Training, Processes, Systems)
- Audit and continuous assessment (also with IA - Internal Audit)
- Decision on irregularities reported by the LTC (incl. voluntary self-disclosures)
- Delegation of tasks and authorities
- Reports to Executive Management
RTC - Regional Trade Compliance
- Understand trade content and regulations in the Region and act as legal advisor in the region
- Liaise, in coordination with Regional/Country Management and the Global Trade Compliance team, with local authorities in trade compliance matters
- Disseminate changes in regional regulations to the Global Trade Compliance Team as well as to the local management and logistics teams
- Escalate Irregularities to Corporate Trade Compliance (CTC)
- Work with Logistics Trade Compliance (LTC) and the local teams to ensure that procedures and processes comply with local trade regulations as well as with Vishay's Global Trade Compliance Program
- Schedule and perform audits in locations in the region LTC - Logistics Trade Compliance
- Execute the Global Trade Compliance Program of the company
- Access to and understanding of trade content/regulations
- Train Compliance Team members
- Execution of regular internal process reviews
- Escalate irregularities to Corporate Trade Compliance (CTC)
- Dissemination of regulatory trade updates
- Audit and continuous assessment
- Report to CTC - Corporate Trade Compliance
- Definition and execution of processes, systems, work instructions
- Requirements Determination Process for Exports - involving Restricted Party Screening, Embargos, EAR, ECCN/Dual Use, ITAR/Military, Block/Unblock Orders pending clarification of requirements/obtaining licenses
- Documentation and Record-Keeping
LEGAL ENTITIES/SUBSIDIARIES - Nominated Compliance Contacts
- Local Management (General Manager) is legally responsible to comply with Customs/Trade Compliance Laws and Regulations
- Ensure Local team is aware and committed to the established corporate/global policies and procedures
- Enable/support local training as identified by CTC and/or LTC
- Control of Technical data as it relates to ITAR (US)
- Enforce established policies as it relates to foreign national visitation (US)
- Active participant in Trade Audits/Internal Process reviews
- Import/Export record keeping as it relates to trade data (Invoices, BOL, AWB's, AES data, etc)
- Consult with LTC (or CTC and LTC) concerning critical trade compliance matters
- Reports to/works with LTC and local Entity Management for trade compliance matters
BUSINESS DIVISIONS - Nominated Compliance Contacts
- Technical Assistance on Classification of Goods
- Responsible for the correct classification of Trade data (HTS, ECCN/Dual Use, ITAR, Military, Origin) for Finished Goods, Raw Material and other physical goods as well as technology, software/data and technical assistance
- Country of origin update notification
- Active participant in Trade Audits as it relates to Material Master Data, Trade data;
- Control of Technical data as it relates to ITAR (US)
- Reports to/works with LTC and Division Management for Trade Compliance matters